REPUBLIC OF THE PHILIPPINES DEPARTMENT OF JUSTICE OFFICE OF THE CITY PROSECUTOR PROSECUTOR Tacloban City City
MARIA JOSEFINA B. CRUZ, CRUZ, Complainant,
I.S. NO. FOR: RAPE UNDER ART. 266 OF THE REVISED PENAL CODE (RPC) (RPC)
-versusTEOFISTO R. ALCON, ALCON, Respondent(s). Respondent(s). x -------------------------------------------------- x
MOTION FOR EXTENSION OF TIME TO SUBMIT COUNTER-AFFIDAVIT COUNTER-AFFIDAVIT ALCON, assisted by Public Attorne Attorney’s y’s Respondent, TEOFISTO R. ALCON, Office (PAO), unto the Honorable City Prosecutor, most respectfully aver(s), that: Respondent on December 22, 2018, received a subpoena from the Prosecutor’s Prosecutor’s Office charging him of the above-stated offense and requiring him to submit his counter-affidavit and other supporting documents within (ten)10 days from receipt thereof; 1.
Today, January 1, 2019, appears to be the last day for the submission of respondent’s respondent’s counter-affidavit and other supporting documents; 2.
This Office only received respondent’s case on December 27, 2018 or merely 5 days before the said deadline; 4. There is a need to further study the case and to gather relevant evidence to support the defense of the Respondent, thus, this request for a period of ten (10) day extension within which to submit the respondent’s respondent’s Counter-Affidavit and other supporting documents; 5. That the filing of this motion is done in good faith and not for purposes of delaying the proceedings of this case but for the reason 3.
above-stated.
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P R A Y E R
WHEREFORE, premises considered, it is respectfully prayed of the WHEREFORE, Honorable Prosecutor that this Motion, praying for an extension of TEN (10) DAYS within which to submit Respondent’s Respondent’s Counter-Affidavit and supporting documents, be granted. granted. January 1, 2019, at the City of Tacloban, Philippines.
PUBLIC ATTORNEY’S OFFICE OFFICE Department of Justice TACLOBAN CITY DISTRICT OFFICE OFFICE By: ATTY. CINDY HAN HAN Public Attorney III #8 Bulwagan ng Katarungan, Magsaysay Blvd., Tacloban City Attys. Roll No . 34380/ April April 1, 2000 IBP OR No.No. 542682/04/02/08/Tacloban City PTR No. 764523/04/04/08/Tacloban City MCLE Compliance No. III-0009876, 1123-2010 Contact No.: 09876453421/ 321-1234 Email address:
[email protected] CONFORME: CONFORME: TEOFISTO R. ALCON
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NOTICE The Clerk Clerk Office of the City Prosecutor, Tacloban City
GREETINGS: Please submit the foregoing motion for the consideration of the Honorable City Prosecutor immediately immediately upon receipt hereof without further oral argument.
ATTY.. CINDY HAN ATTY Copy furnished: MARIA JOSEFINA B. CRUZ
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